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    <title>2010 (8) TMI 23 - DELHI HIGH COURT</title>
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    <description>In a s.68 addition relating to share application money, the HC held that the assessee&#039;s initial onus is discharged by establishing the identity of share applicants (e.g., tax identifiers) and the genuineness of the transaction through banking channels as reflected in its books; thereafter the burden shifts to the Revenue to investigate, and mere non-traceability of applicants at the stated address does not justify invoking s.68. The assessee is not required to prove the &quot;source of source.&quot; As the issue was covered by SC and prior HC precedent in the assessee&#039;s own case, no substantial question of law arose and the Revenue&#039;s appeals were dismissed as relitigation, with an advisory to avoid routine appeals on settled issues.</description>
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      <link>https://www.taxtmi.com/caselaws?id=77452</link>
      <description>In a s.68 addition relating to share application money, the HC held that the assessee&#039;s initial onus is discharged by establishing the identity of share applicants (e.g., tax identifiers) and the genuineness of the transaction through banking channels as reflected in its books; thereafter the burden shifts to the Revenue to investigate, and mere non-traceability of applicants at the stated address does not justify invoking s.68. The assessee is not required to prove the &quot;source of source.&quot; As the issue was covered by SC and prior HC precedent in the assessee&#039;s own case, no substantial question of law arose and the Revenue&#039;s appeals were dismissed as relitigation, with an advisory to avoid routine appeals on settled issues.</description>
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      <pubDate>Mon, 02 Aug 2010 00:00:00 +0530</pubDate>
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